a

GAO

United States General Accounting Office

Report to Congressional Requesters

June 2003 U.S. ATTORNEYS

Controls Over 

Grant-Related 

Activities Should Be 

Enhanced

GAO-03-733
U.S. Attorneys’ grant activities are guided by legal and ethical 

considerations. General guidelines established by the Attorney General in 

1994 and revised in 2001 outline how U.S. Attorneys and their staff can be 

involved in their community’s crime prevention and control efforts, 

including DOJ grant activities. Last year, DOJ issued guidance in response to 

U.S. Attorneys’ questions about their role in relation to two DOJ grant 

programs—Project Safe Neighborhoods and Weed and Seed. In addition, 

through its Executive Office for U.S. Attorneys (EOUSA), DOJ provided 

training on ethical considerations in dealing with grant applicants and 

grantees under both grant programs. 

Although EOUSA has an evaluation program to assess and oversee the 

overall operations of each U.S. Attorney’s Office, the evaluations are not 

designed to assess whether U.S. Attorneys and their staffs are following the 

recently established guidelines. Without a mechanism to make this 

assessment, EOUSA does not have assurance that DOJ guidance 

• is adequately understood, 

• has reached all those who are covered by it, and 

• is correctly applied. 

In addition, federal regulations and procedures call for systematic financial 

disclosure reporting to facilitate the review of possible conflicts of interest 

and ensure the efficient and honest operation of the government. However, 

while GAO did not identify any incidences of conflicts of interest, certain 

individuals—staff in U.S. Attorneys Offices that work with grantees and 

nonfederal members of committees that are appointed by each U.S. Attorney 

to, among other things, assess the merits of grant proposals—are not 

required to disclose whether they are free from actual or apparent conflicts 

of interest. Based on the merits of GAO’s work, DOJ officials stated that 

they would issue a directive to require members of these committees to sign 

a self-certified conflict of interest statement that is to be held on file subject 

to DOJ grant monitoring. 

Ninety-three U.S. Attorneys serve 

94 judicial districts (the same U.S. 

Attorney serves the District of 

Guam and the District of the 

Northern Mariana Islands) under 

the direction of the Attorney 

General. Among other things, the 

Attorney General expects U.S. 

Attorneys to lead or be involved 

with the community in preventing 

and controlling crime including 

efforts to secure Department of 

Justice (DOJ) grant funds and work 

with grantees. 

This report provides information 

about the guidance U.S. Attorneys 

are given in carrying out their 

responsibilities with regard to DOJ 

grants. It makes recommendations 

to assess compliance with guidance 

and to reduce the potential for 

conflicts of interest. 

GAO recommends that the Director 

of the Executive Office for U.S. 

Attorneys take steps to further 

mitigate the risk associated with 

U.S. Attorney involvement in grant 

activities by (1) assessing and 

overseeing compliance with the 

DOJ guidance and (2) requiring 

staff that work on grant-related 

matters to certify they are free 

from conflicts of interest. 

DOJ reviewed a draft of this report 

and had no comments. 

U.S. ATTORNEYS

Controls Over Grant-Related Activities 

Should Be Enhanced 

www.gao.gov/cgi-bin/getrpt?GAO-03-733.

To view the full report, including the scope 

and methodology, click on the link above. 

For more information, contact Paul L. Jones 

at (202) 512-8777 or jonespl@gao.gov. 

Highlights of GAO-03-733, a report to 

Congressional Requesters 

June 2003
Page i GAO-03-733 U.S. Attorneys' Grant Activities 

Letter 1

Results in Brief 3

Background 4

DOJ Guidelines Covering U.S. Attorneys’ Grant Activities 7

DOJ Has Not Established Oversight Mechanisms to Assess and 

Ensure Compliance with Recent Guidelines 10

Conclusions 17

Recommendations 18

Agency Comments and Our Evaluation 18

Appendix I Summary of Guidelines Issued for U.S. Attorneys 

Regarding Grants Awarded under the PSN and 

Weed and Seed Programs 19 

PSN Grants 19

Weed and Seed Grants 20 

Abbreviations 

BJA Bureau of Justice Assistance 

DOJ Department of Justice 

EARS Evaluation and Review Staff 

EOUSA Executive Office for U.S. Attorneys 

EOWS Executive Office for Weed and Seed 

LECC Law Enforcement Coordinating Committee 

OIG Office of Inspector General 

OJP Office of Justice Programs 

PSN Project Safe Neighborhoods 

Contents 

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copyrighted materials separately from GAO’s product. 
Page 1 GAO-03-733 U.S. Attorneys' Grant Activities 

June 10, 2003 

The Honorable F. James Sensenbrenner, Jr. 

Chairman 

The Honorable John Conyers, Jr. 

Ranking Minority Member 

Committee on the Judiciary 

House of Representatives 

The Honorable Chris Cannon 

Chairman 

The Honorable Melvin Watt 

Ranking Minority Member 

Subcommittee on Commercial and Administrative Law 

Committee on the Judiciary 

House of Representatives 

U.S. Attorneys are appointed by the President of the United States, with 

advice and consent of the U.S. Senate. Under the direction of the Attorney 

General, each of the 93 U.S. Attorneys is the chief federal law enforcement 

officer of the United States within his or her particular jurisdiction. During 

fiscal year 2002, the Department of Justice (DOJ) spent about $1.5 billion 

on its 94 U.S. Attorneys Offices to prosecute individuals charged with 

violations of federal criminal law, represent the government in civil cases, 

and collect money and property owed to the government.1

 In addition, U.S. 

Attorneys Offices were involved in initiatives to prevent and control crime 

in their communities, including some supported by DOJ grant funds. 

This report responds to your request that we provide information on U.S. 

Attorneys involvement in DOJ grant programs. To address your request, 

we are reporting on (1) guidance available to U.S. Attorneys and their 

offices in carrying out their responsibilities with regard to DOJ grants and 

(2) oversight of those responsibilities by DOJ. To meet our objectives, we 

interviewed officials with the Executive Office for U.S. Attorneys 

(EOUSA) and Office of Justice Programs (OJP) in Washington, D.C. and 

obtained and reviewed information about the guidance available to and 

 1

A total of 93 U.S. Attorneys serve 94 districts—the same U.S. Attorney serves the District 

of Guam and the District of the Northern Mariana Islands. 

United States General Accounting Office

Washington, DC 20548 
Page 2 GAO-03-733 U.S. Attorneys' Grant Activities 

the oversight of U.S. Attorneys Offices in regard to DOJ grant programs. 

As agreed with your staff, we also visited 10 of the 94 U.S. Attorneys 

Offices and interviewed U.S. Attorneys and their staffs in each office.2

 We 

performed our work from December 2001 to May 2003 in accordance with 

generally accepted government auditing standards. 

U.S. Attorneys Offices carry out their grant-related responsibilities related 

to two DOJ programs—Project Safe Neighborhoods (PSN) and the Weed 

and Seed Program (Weed and Seed). PSN is a multiyear commitment, 

initiated by the President and the Attorney General in fiscal year 2001, to 

take a comprehensive strategic approach to the enforcement of firearms 

laws. To implement this strategy, the Attorney General required each of 

the 94 U.S. Attorneys Offices to support, promote, and implement a 

comprehensive gun violence reduction program within each local district, 

working in partnership with communities and state and local law 

enforcement agencies. Under PSN, DOJ’s OJP awards grant funds to 

organizations that work with PSN task forces, in coordination with the 

U.S. Attorneys Office, to provide support for community outreach, crime 

analysis, development of promising gun violence reduction programs, and 

juvenile-related firearm reduction programs. Grants are awarded based on 

input from the U.S. Attorney and a community based grant selection 

committee, which is comprised of nonfederal law enforcement and 

community leaders that are appointed by the U.S. Attorney. OJP’s Bureau 

of Justice Assistance (BJA) administers the grants awarded to support 

PSN, including monitoring grants once they have been awarded. In fiscal 

year 2002, DOJ awarded about $65 million for grants to support PSN task 

forces. DOJ also expects to award about $60 million in fiscal year 2003 and 

again in fiscal year 2004 to support PSN task forces.3

Weed and Seed is a community based, multiagency program, initiated in 

fiscal year 1991, to “weed out” crime from targeted neighborhoods, then 

“seed” the site with a variety of programs and resources to prevent crime 

from recurring. Weed and Seed sites are provided grants, technical 

assistance, and training to implement programs that will help them deal 

 2

We visited the Districts of Delaware, Nebraska, Nevada, and South Carolina, and the 

Southern District of Indiana; the Western District of Washington; the Central District of 

California; the Eastern District of Pennsylvania; the Western District of Texas; and the 

Eastern District of Virginia. 

3

PSN funds are also used to fund other PSN grant and nongrant activities that do not 

directly involve support of PSN Task Forces, in coordination with U.S. Attorneys Offices. 
Page 3 GAO-03-733 U.S. Attorneys' Grant Activities 

with serious crime in their communities. Under the guidance of the U.S. 

Attorney, federal, state, and local officials work together at each site to 

(1) implement activities designed to reduce drug crimes, gangs, and other 

violent crimes in high crime neighborhoods and (2) revitalize those areas 

by implementing a range of human service programs and economic 

development to keep crimes from recurring. OJP’s Executive Office for 

Weed and Seed (EOWS) has overall responsibility for the Weed and Seed 

Program, including establishing policy and monitoring Weed and Seed 

grants. In fiscal year 2003, DOJ expects to award about $53.9 million for 

grants under the Weed and Seed Program. 

Guidelines established by the Attorney General in January 2001 encourage 

U.S. Attorneys to participate in community crime prevention activities—

including those supported by DOJ grants—through the “establishment of 

coalitions with the community and law enforcement as well as strong and 

real working relationships with other public and private entities.” In so 

doing, the guidelines call for U.S. Attorneys and their staff to remain 

impartial and to avoid even the appearance of an involvement with parties 

and activities that could bring them into conflict with their official duties. 

Last year, DOJ published guidelines for U.S. Attorneys Offices that 

specifically focus on their role in PSN and Weed and Seed. In May and 

December 2002, DOJ issued guidelines for U.S. Attorneys Offices and PSN 

task forces that describe the process they were to follow in securing grant 

funds. Among other things, the guidelines provided U.S. Attorneys Offices 

with step-by-step instructions for working with communities to solicit, 

review, and select proposals for specific PSN grants, including guidance 

on related ethics issues. Also, in December 2002, EOUSA issued guidance 

that discussed, among other things, what U.S. Attorneys Offices are to do 

when working with local community organizations that are seeking and 

administering Weed and Seed grant funds. According to EOUSA officials, 

the decision to issue guidance was not prompted by any particular 

incident; rather, the guidelines resulted from questions U.S. Attorneys and 

their staff raised concerning their roles and responsibilities under the 

programs. EOUSA has also provided training on ethical considerations in 

dealing with grant applicants and grantees under both programs and have 

developed a video that discusses various aspects of the PSN grant 

application process, including the ethical considerations facing each U.S. 

Attorneys Office as they deal with PSN grants. 

An effective internal control process is one that provides management 

with a reasonable level of assurance that agency operating, financial, and 

compliance objectives are being systematically achieved. DOJ components 

Results in Brief 
Page 4 GAO-03-733 U.S. Attorneys' Grant Activities 

have not established oversight mechanisms to assess and ensure 

compliance with the PSN and Weed and Seed guidelines they issued last 

year. Although EOUSA has an evaluation program to assess and oversee 

the overall operations of each U.S. Attorneys Office—including operations 

associated with the management of the PSN and Weed and Seed 

Programs—the evaluations are not designed to assess whether U.S. 

Attorneys and their staffs are following the guidance recently established. 

Federal regulations and procedures also call for systematic financial 

disclosure reporting to, among other things, facilitate the review of 

possible conflicts of interest to guarantee the efficient and honest 

operation of the government. However, EOUSA and BJA have not 

established a reporting mechanism for employees of U.S. Attorneys 

Offices that work with grantees and nonfederal appointees to PSN grant 

selection committees to provide management assurance that these 

individuals are free from actual or apparent conflicts of interest. EOUSA 

officials acknowledged that U.S. Attorneys’ Offices staff could face 

possible conflicts in their dealings with grantees and said they would 

consider ways in which staff could periodically report on any personal, 

financial, or business relationships they might have involving nonfederal 

individuals or organizations. Likewise, based on our work, BJA officials 

said that they would issue a directive that requires selection committee 

appointees to submit a signed self-certified conflict of interest statement 

that will be kept on file for oversight by BJA grant monitors. 

We are recommending that the Attorney General instruct the Director of 

EOUSA and U.S. Attorneys to take steps to (1) assess and oversee 

compliance with PSN and Weed and Seed guidelines and (2) require 

financial disclosure reporting for U.S. Attorneys’ staff that work with 

community organizations on grant-related matters. 

We provided a draft of this report to the Attorney General for comment. 

DOJ did not have any comments on this report. 

U. S. Attorneys serve as the nation’s principal litigators under the direction 

of the Attorney General. U.S. Attorneys conduct most of the trial work in 

which the United States is a party. Under Title 28 U.S.C. 547, U.S. 

Attorneys have three statutory responsibilities: 

• prosecute criminal cases brought by the federal government 

Background 
Page 5 GAO-03-733 U.S. Attorneys' Grant Activities 

• prosecute and defend civil cases in which the United States is a party, 

and 

• collect debts owed the federal government that are administratively 

uncollectible. 

EOUSA was established to provide a liaison between DOJ in Washington, 

D.C., and the 93 U.S. Attorneys. EOUSA provides each U.S. Attorney and 

the 94 U.S. Attorneys Offices general executive assistance and direction, 

policy development, administrative management and oversight, 

operational support, and coordination with other components of DOJ and 

other federal agencies. In fiscal year 2002, U.S. Attorneys’, and EOUSA’s 

budgets were about $1.5 billion and $64.6 million, respectively. 

OJP, the grant making arm of DOJ, provides grants to various 

organizations, including state and local governments, universities, and 

private foundations, that are intended to develop the nation’s capacity to 

prevent and control crime, administer justice, and assist crime victims. 

OJP’s Assistant Attorney General is responsible for overall management 

and oversight of OJP through setting policy and for ensuring that OJP 

policies and programs reflect the priorities of the President, the Attorney 

General, and the Congress. The Assistant Attorney General promotes 

coordination among the various bureaus and offices within OJP.4

 Staff of 

the bureaus and program offices develop OJP grant programs, accept and 

review applications, make grant awards, and manage and monitor grantees 

until the award is closed out. In fiscal year 2002, OJP’s budget was about 

$4.3 billion. 

According to OJP and EOUSA officials, U.S. Attorneys and their staff 

currently are involved in two DOJ programs involving OJP grants—PSN 

and Weed and Seed. As mentioned earlier, BJA is responsible for national 

administration and management of grants awarded under the PSN 

initiative. PSN, which was initiated in fiscal year 2001 by the President and 

the Attorney General, was designed to commit more than $900 million over 

a 3-year period to hire new federal and state prosecutors, support 

 4

OJP’s bureaus and program offices are Bureau of Justice Assistance, Bureau of Justice 

Statistics, National Institute of Justice, Office of Juvenile Justice and Delinquency 

Prevention, Office for Victims of Crime, Office of Police Corps and Law Enforcement 

Education, and Community Capacity Development Office (including the Executive Office 

for Weed and Seed). 

OJP 
Page 6 GAO-03-733 U.S. Attorneys' Grant Activities 

investigators, provide training, and develop and promote community 

outreach efforts all with the goal of focusing community attention and 

energy on reducing gun violence.5

 Under the program, U.S. Attorneys were 

to take the lead in mobilizing federal, state, and local officials in their 

districts by establishing PSN task forces to develop comprehensive gun 

violence reduction strategies or review and enhance existing strategies. 

PSN task forces are to implement these strategies, in part, through the use 

of various OJP grants awarded in each U.S. Attorney’s district. These OJP 

grants are the (1) Research Partner/Crime Analyst Grants to support the 

strategic planning and accountability portion of PSN, (2) Media Outreach 

and Community Engagement Grants to help task forces in their 

community outreach initiatives, (3) Project Sentry Grants to help task 

forces address local juvenile related gun crimes, and (4) Open Solicitation 

Grants to support comprehensive and innovative approaches to reduce 

gun violence in local communities. 

EOWS is responsible for providing national leadership as well as 

management and administration of the Weed and Seed Program, which in 

fiscal year 2002 had a budget of about $59 million. Under the program, U.S. 

Attorneys are to serve as both the main contact to Weed and Seed sites for 

EOWS and as facilitator of the program’s community based coordination 

efforts. Accordingly, U.S. Attorneys are to work with local stakeholders to 

develop and implement a community based, multiagency strategy that 

proposes to “weed out” crime from targeted neighborhoods, then “seed” 

the site with a variety of programs and resources to prevent crime from 

recurring.6

 In fiscal year 2002, there were about 229 Weed and Seed sites 

and the average grant awarded per site was about $200,000. 

 5

Under P.L. 106-553 EOUSA allocated 163 new positions, 113 of which were for attorneys to 

prosecute firearms violations in 62 of the 94 judicial districts to support PSN. In addition, in 

February 2002, the Attorney General assigned a new prosecutor to 93 of the 94 districts and 

placed 1 position in EOUSA to further support the program. 

6

A central tenant of the Weed and Seed Program is for local Weed and Seed sites to develop 

partnerships among federal, state, and local governments and private sector agencies to 

leverage federal Weed and Seed grant funds with additional resources from these partners 

to promote weeding and seeding activities. These additional resources are intended to help 

the site achieve the goal of becoming self-sustaining without Weed and Seed grant funds. 
Page 7 GAO-03-733 U.S. Attorneys' Grant Activities 

Guidelines first established by the Attorney General in 1994 stated that 

U.S. Attorneys and their staff may be involved in their community’s crime 

prevention and control efforts—including efforts to secure DOJ grant 

funds and work with grantees—as long as they subscribe to legal and 

ethical considerations. DOJ components have recently issued related 

guidelines for U.S. Attorneys and their staff that, among other things, 

focuses specifically on their dealings with grant applicants and grantees 

under the PSN and Weed and Seed Programs. According to EOUSA 

officials, DOJ issued program specific guidelines in response to the 

numerous questions by U.S. Attorneys and their staff concerning their role 

in relation to PSN and Weed and Seed. 

U.S. Attorneys are encouraged to be involved in community based 

activities that seek and secure DOJ grant funds as long as they and their 

staff subscribe to legal and ethical considerations commensurate with 

being a government employee, an attorney, and U.S. Attorney.7

 According 

to guidelines established by the Attorney General in 1994 and revised in 

January 2001, U.S. Attorneys are encouraged to engage in community 

based crime prevention and control activities and form coalitions with 

nonfederal, community based organizations, private entities, and law 

enforcement because “promoting crime prevention initiatives enhances 

the presence of the Department of Justice in communities around the 

country and has proven effective in reducing crime.” The guidelines state 

 7

Federal conflict of interest rules are published at 18 U.S.C. § 208 and implementing 

regulations at 5 C.F.R. § 2635.402. Essentially, these rules prohibit employees from taking 

official action in a particular matter involving any entity in which they, or someone whose 

interests are imputed to them, have a financial interest. Imputed interests include (1) the 

interests of the employee’s spouse; (2) minor children; (3) a general partner; (4) an 

organization in which the employee is serving as an officer, director, trustee, general 

partner, or employee; or (5) any person or organization with whom the employee is 

negotiating or has any arrangement concerning prospective employment. In addition, 

Federal Standards of Conduct prohibit employees from acting in a particular matter that 

involves a financial interest of a member of their household or if it involves a person with 

whom the employee has a “covered relationship” (5 C.F.R. § 2635.502). Covered 

relationship is defined to include (1) a person with whom the employee conducts business 

other than routine consumer transactions; (2) a person who is a member of the employees 

household, or who is a relative with whom the employee has a close personal relationship; 

(3) a person for whom the employee’s spouse, parent, or dependent child is serving or 

seeking to serve as an officer, director, trustee, general partner, agent attorney, consultant, 

contractor, or employee; (4) any person for whom the employee has served, within the last 

year, as officer, director, trustee, general partner, agent attorney, consultant, contractor, or 

employee; and (5) an organization in which the employee is an active participant. 

DOJ Guidelines 

Covering U.S. 

Attorneys’ Grant 

Activities 

Attorney General 

Guidelines Encourage U.S. 

Attorneys to Be Active in 

Community Based 

Programs Involving DOJ 

Grants 
Page 8 GAO-03-733 U.S. Attorneys' Grant Activities 

that, when working with nonfederal entities in implementing crime 

prevention initiatives, U.S. Attorneys and their staff are to 

• remain impartial in carrying out their official duties and be careful to 

avoid the appearance of partiality; 

• consider conflicts of interest statutes when crime prevention activities 

involve persons or organizations with whom they have a personal, 

financial, or business relationship; and 

• avoid participation in coalitions that include individuals and nonfederal 

organizations that may be victims, witnesses, subjects, or targets in 

matters pending in their districts. 

Thus, under the Attorney General’s guidelines, U.S. Attorneys may 

convene meetings with other potential coalition participants to discuss 

operating needs, program initiatives, event planning, and other related 

matters, but they are to avoid participating in budget decisions of a 

coalition, including decisions regarding the expenditure of funds that 

could create the appearance that the U.S. Attorney is managing an entity 

outside of DOJ. Also, according to the guidelines, U.S. Attorneys may 

endorse specific coalition-based program initiatives as long as they refrain 

from endorsing specific organizations; give presentations about coalition 

initiatives at fund-raising events as long as the presentation addresses 

official DOJ issues and does not solicit contributions; and participate in 

public service announcements with other coalition members when the 

purpose of the announcement is to further DOJ’s mission and coalition 

initiatives. 

With regard to grants, the guidelines state that U.S. Attorneys may provide 

potential grant applicants with public information regarding sources of 

federal funding and respond to inquiries regarding the grant application 

process. Furthermore, they may draft a letter of recommendation to OJP 

supporting a grant application. According to the guidelines, this letter can 

identify the applicant’s accomplishments and may express the U.S. 

Attorney’s views on whether government program funds should or should 

not be granted to a particular applicant. However, U.S. Attorneys’ names 

are not to appear on grant applications unless required by law, and U.S. 

Attorneys are not to otherwise contact federal agencies on behalf of an 

applicant seeking federal grant monies. 
Page 9 GAO-03-733 U.S. Attorneys' Grant Activities 

DOJ components involved in the PSN and Weed and Seed Programs have 

taken steps to provide specific guidance to U.S. Attorneys and their offices 

in carrying out their grant-related responsibilities. In May 2002, EOUSA 

told U.S. Attorneys and their staff that BJA had published Web based 

guidelines for U.S. Attorneys Offices and PSN task forces to instruct them 

about their role in the process to solicit, review, and select grant 

proposals. According to the memorandum issued by EOUSA’s Director, 

the guidance was designed to provide step-by-step instructions on the 

grant process that included guidance about specific ethics issues. In 

December 2002, EOUSA told U.S. Attorneys and their staff about new PSN 

guidelines—again including guidance about ethics issues—designed to 

cover grants to be awarded in fiscal year 2003. During the same month, the 

EOUSA Director sent a memorandum to all U.S. Attorneys, their senior 

staff, and Law Enforcement Coordinating Committee (LECC) 

Coordinators about U.S. Attorneys Offices’ responsibilities in 

implementing the Weed and Seed Program, including how to deal with 

ethics concerns related to Weed and Seed grant activities.8

 Appendix I 

provides greater detail on the guidelines DOJ components issued for U.S. 

Attorneys Offices on PSN and Weed and Seed during calendar year 2002. 

According to EOUSA officials, the decision to issue guidelines for each 

program resulted from DOJ’s overall effort to develop the PSN Program. 

EOUSA’s Deputy Legal Counsel in EOUSA’s Office of Legal Counsel said 

that the PSN guidance was not prompted by any particular incident; 

rather, it was developed in response to numerous questions about PSNrelated ethics issues from U.S. Attorneys and their staff as the program 

was being developed. The Deputy Legal Counsel said the exercise, 

combined with similar questions by U.S. Attorneys and their staff 

subsequently prompted EOUSA to develop the December 2002 guidance 

for the Weed and Seed Program. 

EOUSA’s Deputy Legal Counsel also said that EOUSA has provided ethics 

training to U.S. Attorneys and their staff on their roles and responsibilities 

 8

According to EOUSA, there are currently 87 LECC Coordinators nationwide. LECC 

Coordinator positions are classified under the General Schedule as GS-12 and GS-13 Law 

Enforcement Coordination Specialists. According to EOUSA officials, LECC 

responsibilities for the PSN and Weed and Seed Program can vary from district to district, 

as determined by the U.S. Attorney and for Weed and Seed sites, the LECC is the individual 

from the district that works most closely with the sites, acting as EOWS’ direct contact 

with the site. Regarding PSN, EOUSA officials said that the LECC Coordinator is able to 

use contacts with law enforcement, including those made through Weed and Seed, to act as 

a liaison between law enforcement and other PSN participants or partners. 

DOJ Has Recently 

Published Guidelines for 

U.S. Attorney Offices 

Related to PSN and Weed 

and Seed Activities 
Page 10 GAO-03-733 U.S. Attorneys' Grant Activities 

as it relates to grants offered and awarded under both programs. In 

January 2002, EOUSA provided a presentation to U.S. Attorneys at the first 

national PSN conference and in April 2002, EOUSA provided the same 

presentation for each districts’ LECC Coordinators at a similar conference. 

The presentation included a discussion of what U.S. Attorneys and their 

staff can and cannot do when participating in the grant process. The 

Deputy Legal Counsel said that ethics training pertinent to the Weed and 

Seed Program was also provided to LECCs during October 2002. Also, in 

December 2002, EOUSA produced and disseminated a video that 

discussed the process U.S. Attorneys are to follow when working with 

PSN task forces during the grantee selection and application process. 

EOUSA’s Legal Counsel and Deputy Legal Counsel also indicated that they 

believe that training, available guidance on ethics issues, and staff 

awareness about standards of conflicts and actual or apparent conflicts of 

interest are sufficient to ensure that ethical lapses will not occur. They 

said that they were unaware of any ethical lapses and said that if questions 

were raised, DOJ’s Office of Inspector General (OIG) would investigate 

them. OIG staff we contacted who were responsible for dealing with 

ethical issues at DOJ said they were aware of only one complaint involving 

a U.S. Attorney and the Weed and Seed Program and none regarding PSN. 

An effective internal control process is one that provides management 

with a reasonable level of assurance that agency operating, financial, and 

compliance objectives are being achieved on a systematic basis. EOUSA 

has an evaluation program to assess and oversee the overall operations of 

each U.S. Attorneys Office—including operations associated with the 

management of the PSN and Weed and Seed Programs—but the 

evaluations are not designed to assess compliance with the PSN and Weed 

and Seed guidelines recently issued. Similarly, federal regulations and 

procedures call for systematic financial disclosure reporting to, among 

other things, facilitate the review of possible conflicts of interest to 

guarantee the efficient and honest operation of the government. However, 

DOJ has not established a financial disclosure reporting mechanism for 

certain individuals—employees of U.S. Attorneys Offices that work with 

grantees and potential grantees and nonfederal appointees to PSN grant 

selection committees—to provide management assurance that these 

individuals are free from actual or apparent conflicts of interest. 

DOJ Has Not 

Established Oversight 

Mechanisms to Assess 

and Ensure 

Compliance with 

Recent Guidelines 
Page 11 GAO-03-733 U.S. Attorneys' Grant Activities 

According to the Comptroller General’s Standards for Internal Control in 

the Federal Government,9

 internal control activities are the policies, 

procedures, techniques, and mechanisms that enforce management’s 

directives. They include, for example, steps to set the specific standards or 

criteria to be achieved by staff as well as steps that provide management 

the information to determine on a routine basis whether the standards are 

being met and to take corrective action when they are not. EOUSA has an 

evaluation program to assess and oversee the overall operations of each 

U.S. Attorneys Office that includes an assessment of the office’s 

involvement in and performance related to the Weed and Seed and PSN 

Programs. However, the evaluations are not designed to assess 

compliance with the Weed and Seed and PSN guidance related to ethical 

concerns that EOUSA recently issued. 

Under 28 C.F.R. Part 0.22, EOUSA is to evaluate the performance of the 

U.S. Attorneys Offices, make appropriate reports, and take corrective 

actions if necessary. EOUSA’s Evaluation and Review Staff (EARS) is 

responsible for the evaluation program, which, according to EOUSA, is an 

internal review program designed, among other things, to examine 

management controls and prevent waste, loss, unauthorized use, or 

misappropriation in federal programs, as required under the Federal 

Manager’s Financial Integrity Act. EARS evaluations are conducted in each 

of the 94 U.S. Attorneys Offices every 3 years by teams of experienced 

Assistant U.S. Attorneys, and administrative and financial litigation 

personnel from other U.S. Attorneys Offices.10 According to EOUSA’s 

Assistant Director for EARS, these assessments focus on personnel, 

management, and workload issues in individual U.S. Attorneys Offices and 

include, among other things, an assessment of the management and 

operations of the local Weed and Seed and PSN Programs. 

 9

U.S. General Accounting Office, Standards for Internal Control in the Federal 

Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999), which was issued 

under 31 U.S.C. 3512 (formerly known as the Federal Manager’s Financial Integrity Act), 

established the framework for internal (or management) control in the federal government. 

An effective internal control process is one that provides management with a reasonable 

level of assurance that agency operating, financial, and compliance objectives are being 

achieved on a systematic basis. 

10EOUSA officials told us that, in fiscal year 2001, EARS teams conducted evaluations in 

30 U.S. Attorneys Offices. EARS teams also conducted 32 follow-up reviews in other offices 

to ensure that issues identified in earlier visits were resolved. 

EOUSA Does Not Assess 

Compliance with Recent 

PSN and Weed and Seed 

Guidelines 
Page 12 GAO-03-733 U.S. Attorneys' Grant Activities 

Our review of EARS guidelines show that when evaluating the 

management of the PSN and Weed and Seed Programs in U.S. Attorneys 

Offices, review teams were to focus on task force or committee 

management issues rather than compliance with the guidelines recently 

published. For example, the template for the PSN part of the EARS review 

instructs EARS reviewers to examine, among other things, whether the 

PSN strategy had been implemented. If so, evaluators were instructed to 

provide information on a variety of matters, including 

• the names of the PSN coordinators and the litigation units, sections, or 

branch offices where they serve; 

• the nature of the partnerships that have been developed with federal, 

state, and local law enforcement and whether the partnerships are 

districtwide or tailored to meet the individual needs or problems facing 

branch offices; 

• the community outreach activities associated with PSN; 

• the number of specially allocated attorney and support staff positions 

allocated to the office and whether they have been filled; and 

• examples of successes achieved under the program. 

For the Weed and Seed Program, the template instructs review teams to 

respond to the following five questions: 

• Does the district have a funded Weed and Seed Program? If so, 

describe the site, its organization, committees, management, programs, 

and initiatives. 

• Who in the U.S. Attorneys Offices supervises and works with the Weed 

and Seed Program? 

• What is the U.S. Attorneys’ role in the Weed and Seed Program? 

• What other U.S. Attorneys Offices staff, such as the LECC or Assistant 

U.S. Attorneys have a role in the Weed and Seed Program? 

• Do you know of any problems or concerns with the Weed and Seed 

Program? 

EOUSA’s Assistant Director for EARS said that reviews for both programs 

were broad based management reviews and were not designed to be 
Page 13 GAO-03-733 U.S. Attorneys' Grant Activities 

audits of the programs. The Assistant Director also said that there are 

plans to revise the PSN part of EARS to include an evaluation of gun-crime 

data that is to be reported to the Attorney General twice yearly, but there 

are no similar plans to revise the Weed and Seed part of EARS. Regarding 

the recently issued PSN and Weed and Seed guidelines, the Assistant 

Director said that there are no plans to revise EARS to assess compliance 

with the guidelines and determine whether they are working as intended. 

Staff in U.S. Attorneys Offices can be delegated responsibility to lead or 

work with community organizations that receive Weed and Seed grant 

funds, but these staff are not required to file disclosure forms. These forms 

might reveal relationships that could be actual or potential conflicts of 

interest. According to 5 C.F.R. 2634.904, each officer or employee whose 

position is classified at GS-15 or below or at a rate of pay that is less than 

120 percent of the minimum rate of pay for GS-15, is required to file a 

confidential financial disclosure report if the agency concludes that the 

duties and responsibilities of the employee’s position require the employee 

to: 

• participate personally and substantially through decision or exercise of 

judgment, in taking a government action regarding contracting or 

procurement; administering or monitoring grants, subsidies, licenses, 

or other federal conferred financial or operational benefits; regulating 

or auditing any nonfederal entity; or other activities in which the final 

decision or action will have a direct and substantial economic effect on 

the interests or nonfederal entity or 

• avoid involvement in a real or apparent conflict of interest, and to carry 

out the purpose behind any statute, executive order, rule, or regulation 

applicable or administered by that employee. 

According to 5 C.F.R. 2634.901, these reports are designed to (1) assist an 

agency in administering its ethics program and counseling its employees 

and (2) facilitate the review of possible conflicts of interest to guarantee 

the efficient and honest operation of the government.11

 11According to this regulation, the purpose of such reporting is to complement the public 

reporting system established by the Ethics in Government Act of 1978, as amended, which 

requires that high-level officials in the executive branch report certain financial interests 

publicly to ensure that every citizen can have confidence in the integrity of the federal 

government. 

U.S. Attorney Staff That 

Work with Grantees Not 

Required to File 

Confidential Financial 

Disclosure Forms 
Page 14 GAO-03-733 U.S. Attorneys' Grant Activities 

During our review, we examined the most recent summary of EARS 

reports dated between June 1997 and April 2000, for the 10 U.S. Attorneys 

Offices we visited. In some of these districts, U.S. Attorneys participated 

on the Weed and Seed steering committee, while in others, Assistant U.S. 

Attorneys or LECC Coordinators were delegated responsibility for 

working with Weed and Seed committees, and according to one report, 

“run” the Weed and Seed Program. None of the EARS reports addressed 

any involvement with the PSN program because when the reviews were 

completed, PSN had not been implemented. Our work in the 10 districts 

also showed that 9 of the districts had active Weed and Seed sites in place, 

and in some districts, new Weed and Seed sites were under consideration. 

Among the districts that had active Weed and Seed sites, some of the U.S. 

Attorneys told us that they actively worked with Weed and Seed 

committees, whereas others delegated responsibility to an Assistant U.S. 

Attorney or to LECC Coordinators. For example, in one district the LECC 

Coordinator represented the U.S. Attorney on the Weed and Seed 

committee, while in another district the LECC Coordinator helped manage 

the Weed and Seed sites day-to-day operations. 

Given recent EOUSA, BJA, and EOWS efforts to publish PSN and Weed 

and Seed guidelines and train U.S. Attorneys and their staff about ethical 

concerns, we asked if U.S. Attorneys and their staff that deal with 

potential grant applicants and grantees were required to file financial 

disclosure statements. They provided information, published on DOJ 

internal Web pages, which showed that under current DOJ guidelines: 

• U.S. Attorneys, Assistant U.S. Attorneys in supervisory positions, 

Senior Litigation Counsels, Special Government Employees, and 

Schedule C employees are required to file a Public Financial Disclosure 

Report within 30 days of assuming their covered position and annually 

thereafter. 
Page 15 GAO-03-733 U.S. Attorneys' Grant Activities 

• All line Assistant U.S. Attorneys and special Assistant U.S. Attorneys 

are required to file a Confidential Conflict of Interest Certification 

Form to certify that they have no conflict of interest in each matter 

they undertake.12

• Employees occupying positions in which they exercise significant 

judgment on matters that have an economic effect on the interests of a 

nonfederal entity are required to file a confidential financial disclosure 

report within 30 days on entering a covered position and every year by 

October 31, including positions where duties involve contracting, 

procurement, administering grants, regulating, or auditing a nonfederal 

entity or other activities in which the final decision or action will have 

a direct and substantial economic effect on the interests of any 

nonfederal entity. 

EOUSA’s Deputy Legal Counsel also told us that LECC Coordinators and 

Assistant U.S. Attorneys that work with organizations involving grantees 

are not required to file confidential disclosure forms because they are not 

responsible for administering or monitoring grants. The Deputy Legal 

Counsel pointed out that employees in U.S. Attorneys Offices are not 

supposed to monitor grants. The Deputy Legal Counsel said that the Weed 

and Seed guidelines instruct employees to not act on behalf of EOWS; 

rather, they are to notify EOWS of any issues that may arise during the 

course of the grant relationship and EOWS is to handle the matter under 

its own procedures. Nonetheless, the Deputy Legal Counsel acknowledged 

that U.S. Attorneys Office staff that work with grantees under the Weed 

and Seed Program might encounter situations that could be perceived as 

real or apparent conflicts of interest. Furthermore, the Deputy Legal 

Counsel and EOUSA’s Deputy Director said that, based on our inquiry, it 

might be worthwhile considering a change to procedures so that LECC 

Coordinators would be required to file confidential disclosure statements. 

The Deputy Legal Counsel added that Assistant U.S. Attorneys are already 

required to file the confidential certification form for each matter they are 

involved with and was not clear whether involvement in a community 

 12According to EOUSA officials, in 1994, the Office of Government Ethics approved DOJ’s 

use of the Confidential Conflict of Interest Certification Form in lieu of a confidential 

financial disclosure report. According to DOJ’s internal Web site that discusses the form, 

the form is designed to continually impress on each Assistant U.S. Attorney the affirmative 

duty of complying with all ethics laws and regulations. DOJ requires that Assistant U.S. 

Attorneys assigned to each case complete the form and maintain it in the case file. 
Page 16 GAO-03-733 U.S. Attorneys' Grant Activities 

Weed and Seed activity related to grants would constitute a matter 

covered by the certification form.13

In developing the PSN grant program, BJA modeled the PSN selection 

committee process after its peer review process, where peer review 

committees are used to assess the merits of the grant application and 

make recommendations about worthy grant applications. However, 

whereas BJA has established a process to screen peer reviewers for actual 

or apparent conflicts of interest before they are appointed to peer review 

committees, it has not established a similar process for members of PSN 

selection committees. 

According to a BJA project manager, BJA uses a multistep process to 

screen potential peer reviewers for conflict of interest in reviewing 

applications for grants. BJA hires a peer review contractor who is 

responsible for conducting a preliminary screening of potential peer 

reviewers for conflicts of interest based on guidelines established by BJA. 

Once past the preliminary screening, peer reviewers are asked to selfidentify any conflicts of interest by signing a certification statement. 

EOUSA’s PSN coordinator told us that BJA has delegated its peer review 

authority to U.S. Attorneys and, as discussed earlier, BJA has issued 

guidance that includes the steps the U.S. Attorneys are to follow when 

appointing members of the selection committee—peer reviewers for PSN 

grants. BJA’s guidance states that the selection committee can include any 

or all of the other members of the PSN task force, except the U.S. 

Attorney, a member of his or her staff, or any federal employee, as long as 

their participation does not represent an actual or apparent conflict of 

interest. The guidance further reminds the U.S. Attorneys that the 

Standards of Conduct and Conflict of Interest Rules that apply to him or 

her and their staff also apply to members of the selection committee. 

However, unlike the peer review process employed by BJA for other grant 

programs, U.S. Attorneys are not required to screen the selection 

 13During our review, we also noted that the U.S. Attorney manual specifically calls for the 

staff of U.S. Attorneys Offices to file confidential financial disclosure forms if they review 

grant applications. The manual uses Weed and Seed grants as an example. EOUSA’s Deputy 

Legal Counsel told us that this provision would not apply to the staff of U.S. Attorneys 

Offices because they do not review grant applications. Subsequent to that conversation, 

EOUSA’s Deputy Director told us that, since the language in the U.S. Attorney’s manual 

was inaccurate, EOUSA had removed the language from the manual. 

PSN Selection Committee 

Members Are Not 

Screened for Actual or 

Apparent Conflicts of 

Interest 
Page 17 GAO-03-733 U.S. Attorneys' Grant Activities 

committee members they appoint for actual or apparent conflicts of 

interests, nor are committee members asked to self-identify any actual or 

apparent conflicts of interest. 

Our discussions with BJA and EOUSA officials responsible for PSN 

indicated that the lack of a mechanism for identifying actual or apparent 

conflicts of interest among selection committee members was not a 

problem because they believe (1) appointees from these organizations 

would likely be covered by their own ethical guidance governing their 

capacity as a selection committee member and (2) the geographic area 

covered by individual PSN grants is so small that local jurisdictions would 

not select someone to serve on the selection committee that has a vested 

interest in who the grants are awarded to. BJA’s Director of the Programs 

Division told us that, when BJA developed the guidelines for PSN selection 

committees, BJA had not thought of including a requirement that selection 

committee members submit a signed self-disclosure conflict of interest 

statement. The Director of the Programs Division said that, based on our 

inquiry it might be useful to include some type of requirement for conflict 

of interest reporting to add an additional level of assurance about the 

integrity of the PSN Program. Accordingly, in April 2003, the Director, BJA 

Programs Division, said that BJA would issue a directive requiring PSN 

fiscal agents to collect a signed self-certified conflict of interest statement 

from PSN selection committee members. Fiscal agents would be required 

to maintain the statements on file subject to BJA review in their capacity 

as grant monitors. 

DOJ efforts to provide guidance to U.S. Attorneys Offices regarding their 

involvement in activities associated with grants awarded under the PSN 

and Weed and Seed Programs are notable. However, as U.S. Attorneys and 

their staff become more heavily involved in these grant programs, they 

could increasingly encounter actual or apparent conflicts of interest that 

could undermine the integrity of the programs both within districts and 

nationwide. Without a mechanism for monitoring U.S. Attorneys Offices’ 

compliance with available guidance, DOJ does not have reasonable 

assurance that its steps taken to date—such as the issuance of guidance, 

ethics training, and video presentations—are adequately understood and 

have reached all those who are covered by this guidance. DOJ 

components, such as EOUSA and BJA, are also not positioned to 

determine (1) if the guidelines are correctly applied and actually and 

systematically achieving the end result of preventing actual or apparent 

ethical conflicts or (2) whether guidelines related to grant activities could 

be clarified, strengthened, or improved. In addition, the absence of 

Conclusions 
Page 18 GAO-03-733 U.S. Attorneys' Grant Activities 

confidential financial disclosure reporting for U.S. Attorneys Office 

employees that work with grantees hinders the U.S. Attorneys ability to 

(1) fully administer these programs in the context of ethics considerations 

and (2) identify possible conflicts of interest to guarantee the efficient and 

honest operation of the government. 

We recommend that the Attorney General instruct the Director of EOUSA 

and U.S. Attorneys to take steps to further mitigate the risk associated 

with U.S. Attorneys Offices’ involvement in the grant components of the 

PSN and Weed and Seed Programs. Specifically, we recommend that 

EOUSA and U.S. Attorneys (1) establish a mechanism to assess and 

oversee compliance with recently issued guidelines pertaining to the grant 

activities of U.S. Attorneys Offices and ensure that the guidelines are 

working as intended and (2) require that U.S. Attorneys’ staffs who work 

with community organizations on grant-related matters be required to file 

financial disclosure reports certifying that they are free from conflicts of 

interest. 

On May 13, 2003, we requested comments on a draft of this report from the 

Attorney General. On May 19, 2003, Department of Justice officials 

informed us that they had no comments on the report. 

Copies of this report will be made available to other interested parties. 

This report will also be available on the GAO Web site at 

http://www.gao.gov. 

If you have any questions, please contact my Assistant Director, John F. 

Mortin, or me at (202) 512-8777. You may also contact Mr. Mortin at 

mortinj@gao.gov, or me at jonespl@gao.gov. Key contributors to this 

report were Daniel R. Garcia, Grace Coleman, and Maria Romero. 

Paul L. Jones 

Director, 

Homeland Security and Justice 

Recommendations 

Agency Comments 

and Our Evaluation 
Appendix I: Summary of Guidelines Issued for 

U.S. Attorneys Regarding Grants Awarded 

under the PSN and Weed and Seed Programs 

Page 19 GAO-03-733 U.S. Attorneys' Grant Activities 

The following paragraphs summarize the guidelines the Department of 

Justice (DOJ) issued for U.S. Attorneys and their staff during calendar year 

2002 regarding their role in working with grants and grantees awarded 

under the Project Safe Neighborhoods (PSN) and Weed and Seed 

Programs. 

During 2002, DOJ issued two sets of guidelines for U.S. Attorneys and PSN 

task forces in carrying out their responsibilities under PSN. Under the May 

2002 PSN guidelines, each U.S. Attorneys Office was instructed to work 

with interested federal, state, and local officials to form a PSN task force, 

chaired or co-chaired by the U.S. Attorney, to develop a comprehensive 

strategic plan. As part of this process, the task force was to formulate its 

overall mission and goals after which the U.S. Attorney was instructed to 

designate a selection committee to (1) review eligible grant proposals and 

(2) select a single grantee for Research Partner/Crime Analyst and Media 

Outreach and Community Engagement grants funded in fiscal year 2002. 

The guidelines stated that the selection committee was not to include 

members of the U.S. Attorneys’ staff, but could include other members of 

the task force as long as their participation did not represent an actual or 

apparent conflict of interest. In addition, the guidelines instructed the U.S. 

Attorney to 

• certify to the selection committee, based on the recommendations of 

the task force, whether potential grantees are suitable candidates for 

federal funding1

 and 

• convey the committee’s choice to the Bureau of Justice Assistance 

(BJA), along with a letter from the U.S. Attorney, certifying that (1) the 

potential grant recipient is free from allegations of criminal misconduct 

and current investigation and (2) the applicant’s proposal supports the 

PSN task force activities, missions, and goals. 

In December 2002, the Executive Office for U.S. Attorneys (EOUSA) 

announced that BJA had issued similar guidelines for reviewing and 

selecting applicants for grants funded in fiscal year 2003. As before, U.S. 

Attorneys and their staff were instructed to work with the PSN task force 

and, among other things, the U.S. Attorney was to designate a selection 

 1

The U.S. Attorney was to certify to the selection committee before the committee 

reviewed and selected potential grantees. 

Appendix I: Summary of Guidelines Issued 

for U.S. Attorneys Regarding Grants Awarded 

under the PSN and Weed and Seed Programs 

PSN Grants 
Appendix I: Summary of Guidelines Issued for 

U.S. Attorneys Regarding Grants Awarded 

under the PSN and Weed and Seed Programs 

Page 20 GAO-03-733 U.S. Attorneys' Grant Activities 

committee—not comprised of the U.S. Attorneys’ staff or federal 

employees—to choose a grantee. Unlike the earlier guidelines, the 

selection committee was to (1) choose a single grantee to act as fiscal 

agent for the PSN strategy and (2) determine what portions of the PSN 

strategy should be funded and to whom after the grant proposal had been 

approved by BJA.2

 BJA’s guidelines for both fiscal years also included 

hyperlinks to guidance EOUSA had issued for U.S. Attorneys and their 

staff earlier in the year. EOUSA’s guidelines were similar to the Attorney 

General’s guidelines, but they focused specifically on numerous ethics and 

legal issues they need to consider in relation to their involvement with the 

PSN Program. For example, similar to the Attorney General’s guidelines 

discussed earlier, U.S. Attorneys are expected to express their views if 

there is any reason why a particular applicant is an inappropriate 

candidate for PSN funds, but they are prohibited from appearing before 

the Office of Justice Programs on behalf of an applicant seeking grant 

monies associated with PSN. 

In December 2002, EOUSA also issued guidance that outlined the roles 

and responsibilities of U.S. Attorney’s and their staff regarding the Weed 

and Seed Program.3

 Similar to the Attorney General’s and EOUSA’s PSN 

ethics guidelines, EOUSA’s Weed and Seed guidance covered topics 

ranging from working with nonprofit organizations to prohibitions against 

fundraising and listed what activities U.S. Attorneys and their staff can 

perform in support of the Weed and Seed Program. In regard to grants, the 

guidance stated that U.S. Attorneys and their staff may, among other 

things 

 2

According to BJA guidelines, the selection committee may select any government 

agency—such as a state agency or local jurisdiction—or a legal nonprofit organization to 

be the fiscal agent. The guidelines stated that selection committees are free to select any 

organization or establish a new nonprofit agency. However, the guidelines encouraged 

selection committees to select established organizations that have experience 

administering grant funds. According to BJA, the grant funds, once awarded by BJA, may 

be used for any number of purposes—such as targeting new prosecutors to key areas or 

augmenting task force research and outreach efforts—consistent with the local PSN 

strategy and at the discretion of the selection committee. 

3

EOWS had guidance in place for the process to be followed in securing and administering 

Weed and Seed grants, but the guidance was not directed at U.S. Attorneys Offices. Rather, 

it was designed to assist communities and stakeholders in their efforts to secure grant 

funding under the Weed and Seed Program and briefly discussed the role of the U.S. 

Attorney in that process. 

Weed and Seed Grants 
Appendix I: Summary of Guidelines Issued for 

U.S. Attorneys Regarding Grants Awarded 

under the PSN and Weed and Seed Programs 

Page 21 GAO-03-733 U.S. Attorneys' Grant Activities 

• serve as that chair or co-chair of the Weed and Seed Steering 

Committee; 

• certify to the Executive Office for Weed and Seed (EOWS) via a “letter 

of intent” that a potential Weed and Seed site can receive “official 

recognition;” that is the site has developed a strategy sufficient to make 

them eligible to apply for a Weed and Seed grant; 

• review Official Recognition applications and prepare a cover letter for 

submission to EOWS supporting the site and its strategy; 

• review funding applications to ensure technical accuracy and 

consistency with the Weed and Seed strategy; 

• sign a statement of support for the Weed and Seed strategy; and 

• supervise the site, as chair or co-chair of the steering committee, 

throughout the life of the initiative. 

The Weed and Seed guidelines also instructed U.S. Attorneys that, among 

other things, they may not become advocates for individual grant 

applicants; communicate with or appear before any federal agency on 

behalf of a nonprofit organization; or draft grant proposals or applications. 

Furthermore, U.S. Attorneys were told that they are authorized to assist 

EOWS in monitoring the performance of the project under the grant to 

ensure federal grant dollars are not misused, but they are not to act on 

EOWS’ behalf. The guidelines stated that U.S. Attorneys are to inform 

EOWS of site implementation problems or irregularities to enable EOWS 

to take appropriate action. 

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